2017 July California Bar Forum

[netrag]

Did everyone address hearsay on the second question?

In the essays? Yup. I saw 2 hearsay within a hearsay issues. One was admissible (opponent party statement/admission) within a business record and the other inadmissible (I think statement of a belief -- also, it was irrelevant).

Also did this analysis, but I forgot about the CA specific rules, so I pretended they were the same after stating hearsay was exempt from Prop 8.

How did you come out on right to jury trial re: Civ Pro & proximate cause on the following q?

Fml...I totally just threw a few sentences in there on hearsay. Welp

You'll be fine. I wrote two sentences on motion to compel. I thought the remedies question was more difficult, but never learned remedies until earlier this month and was not expecting it to show up.

[maxmartin]

Did everyone address hearsay on the second question?

In the essays? Yup. I saw 2 hearsay within a hearsay issues. One was admissible (opponent party statement/admission) within a business record and the other inadmissible (I think statement of a belief -- also, it was irrelevant).

Also did this analysis, but I forgot about the CA specific rules, so I pretended they were the same after stating hearsay was exempt from Prop 8.

How did you come out on right to jury trial re: Civ Pro & proximate cause on the following q?

Why Prop 8 has anything to do with it? It is a civil trial. I don't think you need to analyze hearsay at all.

[netrag]

Did everyone address hearsay on the second question?

In the essays? Yup. I saw 2 hearsay within a hearsay issues. One was admissible (opponent party statement/admission) within a business record and the other inadmissible (I think statement of a belief -- also, it was irrelevant).

Also did this analysis, but I forgot about the CA specific rules, so I pretended they were the same after stating hearsay was exempt from Prop 8.

How did you come out on right to jury trial re: Civ Pro & proximate cause on the following q?

Why Prop 8 has anything to do with it? It is a civil trial. I don't think you need to analyze hearsay at all.

Woops. Thought it was mostly CA evidence and PR: privileges, hearsay, a.c. confidentiality (and the motion to compel was Cal Civ Pro), fees, etc.

[maxmartin]

Did everyone address hearsay on the second question?

In the essays? Yup. I saw 2 hearsay within a hearsay issues. One was admissible (opponent party statement/admission) within a business record and the other inadmissible (I think statement of a belief -- also, it was irrelevant).

Also did this analysis, but I forgot about the CA specific rules, so I pretended they were the same after stating hearsay was exempt from Prop 8.

How did you come out on right to jury trial re: Civ Pro & proximate cause on the following q?

Why Prop 8 has anything to do with it? It is a civil trial. I don't think you need to analyze hearsay at all.

Woops. Thought it was mostly CA evidence and PR: privileges, hearsay, a.c. confidentiality (and the motion to compel was Cal Civ Pro), fees, etc.

I just don't see it as Evidence at all. Foe me it feels like 100% PR, PR covers all the privilege, confidentiality stuff.

[bmmccb223]

does a judge need to give detailed opinions as to law and fact for summary judgment? can a judge order summary judgment and then vacate and amend later? can a judge do lickity splits while ordering summary judgment? can a judge affect summary judgment even though the defendant winked twice? what's the standard of review on winking? substantial error? jk that's not a thing, but then again maybe it is

I had two of those. Lmao though.

quote="whats an updog"]

Barbri "you'll see one to two Summary Judgnent Qs"
MBE: here's 5000 of them

Lol I didn't know what dispositive meant

At one point I filled in 5 "D" bubbles in a row, almost cried when I saw that.

A state can require public schools at some point Btwn elementary and HS


There was one evidence Q that was alone 1 full page long, lol wtf

It's over, I honestly don't know anyone that said, I feel like I'm gonna pass, everyone just shared that notion of, "I just put my head down, answered the best I could, wrote the best I could and when I looked up 3 hours flew"

I hope we all pass and move on

yo, so many Ds and also sets of 3s of Cs and As too. made me think i for sure fucked up. even went back and checked some, but sometimes you either know the answer or you don't. and if you don't, you just gotta guess. shit show, blood bath, whatever you call it, the NCBE and the bar exam as a whole is a dumb fucking scam. it is not a proper test of one's ability to practice the law. not by a long shot. and 4 months to determine the score? jesus, what year are we living in

I also had a 5 D row.

[fredofred]

For people that use baressays and those other sites, is it generally the case that you can still get a 65 if you execute, say 4/5 issues well?

I'm really unclear how many essays out of the bunch typically get a 55 vs. a 70 vs. a 50 etc. I didn't take a class and so I'm at a loss for some of the nuances.

The conventional wisdom seems to suggest that you need a 65 and that the one-timers calculator is hopelessly optimistic. is there a way to estimate provided by another source? It looks like the February exam had one of the lowest mean scores in recent memory; what do you think the mean is for this one? Assuming average essays, does anyone feel like they have a sense what MBE score would be needed to pass?

Thanks everyone and good luck.

[esq]

For people that use baressays and those other sites, is it generally the case that you can still get a 65 if you execute, say 4/5 issues well?

I'm really unclear how many essays out of the bunch typically get a 55 vs. a 70 vs. a 50 etc. I didn't take a class and so I'm at a loss for some of the nuances.

The conventional wisdom seems to suggest that you need a 65 and that the one-timers calculator is hopelessly optimistic. is there a way to estimate provided by another source? It looks like the February exam had one of the lowest mean scores in recent memory; what do you think the mean is for this one? Assuming average essays, does anyone feel like they have a sense what MBE score would be needed to pass?

Thanks everyone and good luck.

From the statistics that have been discussed on by bar prep companies, 55 and 50 are where about 60% of the essays end up. 75 is rarely awarded, about 5% of the time. I assume this means that about 25ish % land in 65, and not many land in 70, 45, and 80 and above is reserved for those who walk on water.

I'm also not sure about one-timers calculation, but the goal is to get about 65% right on the MBE (probably 130 raw), but at least 60% right (120 minimum) and if you write well you might survive.

[dredd16]

For people that use baressays and those other sites, is it generally the case that you can still get a 65 if you execute, say 4/5 issues well?

From what a former bar grader told me, yes if you miss a minor issue. If it's a major issue, that's another story.

The problem is what's major and minor? There are some issues that could be either.

[fredofred]

It seems like these crossover type questions will be harder to grade since there are many reasonable directions you could push a certain said of facts. On a few, I felt like I went down road A but I could have gone down b or c, with as much to go on. A Stanford prof told me he failed the first time. This system is so absurd.

[varcom24]

Did everyone address hearsay on the second question?

In the essays? Yup. I saw 2 hearsay within a hearsay issues. One was admissible (opponent party statement/admission) within a business record and the other inadmissible (I think statement of a belief -- also, it was irrelevant).

Also did this analysis, but I forgot about the CA specific rules, so I pretended they were the same after stating hearsay was exempt from Prop 8.

How did you come out on right to jury trial re: Civ Pro & proximate cause on the following q?

Why Prop 8 has anything to do with it? It is a civil trial. I don't think you need to analyze hearsay at all.

Woops. Thought it was mostly CA evidence and PR: privileges, hearsay, a.c. confidentiality (and the motion to compel was Cal Civ Pro), fees, etc.

I just don't see it as Evidence at all. marry me it feels like 100% PR, PR covers all the privilege, confidentiality stuff.

I agree with not seeing it as an evidence question at all. I thought it was more about understanding the distinctions between A-C privilege and an atty's duty of confidentiality. The CA distinction about the privilige was enough for me to justify why they wanted CA-specific law.

Obviously I could be way off here. I just think that the essays tended to really tee up the issues (like the fraud complaint standard), and it's impossible to do a hearsay analysis without knowing what exactly the attorney would be saying in testimony, or for what purpose it was being offered. Seems strange to me that they'd want us to essentially write a hearsay question ourselves then answer it.

[jman77]

Did everyone address hearsay on the second question?

In the essays? Yup. I saw 2 hearsay within a hearsay issues. One was admissible (opponent party statement/admission) within a business record and the other inadmissible (I think statement of a belief -- also, it was irrelevant).

Also did this analysis, but I forgot about the CA specific rules, so I pretended they were the same after stating hearsay was exempt from Prop 8.

How did you come out on right to jury trial re: Civ Pro & proximate cause on the following q?

Yeah, I realize now that I forgot to write about the CA distinction RE: opinions and diagnoses. I still think the opinion about her being a good witness would be irrelevant, though. As has been noted by someone else, Prop 8 only applies in criminal cases.

In the contracts question, I said the damages claim would be entitled to jury trial but the equitable claim (SP) would not. I threw in some sentences about how if the two claims were joined, the jury trial would come first and the court would be bound by findings of fact by the jury in the equitable claim trial.

In the torts question, I said no proximate cause unless the court adopted the "zone of danger" doctrine. I did see the ultra hazardous issue (and also threw in strict product liability as a losing theory). However, I only talked about pure comparative negligence in the allocation subquestion and forgot to discuss partial comparative negligence. I was already 1 hour and 10 minutes into the question and needed to get to the MPT.

Incidentally, I had to write the MPT as Softest stopped working for me after I had typed in my torts answers.

[jman77]

Did everyone address hearsay on the second question?

In the essays? Yup. I saw 2 hearsay within a hearsay issues. One was admissible (opponent party statement/admission) within a business record and the other inadmissible (I think statement of a belief -- also, it was irrelevant).

Also did this analysis, but I forgot about the CA specific rules, so I pretended they were the same after stating hearsay was exempt from Prop 8.

How did you come out on right to jury trial re: Civ Pro & proximate cause on the following q?

Why Prop 8 has anything to do with it? It is a civil trial. I don't think you need to analyze hearsay at all.

Woops. Thought it was mostly CA evidence and PR: privileges, hearsay, a.c. confidentiality (and the motion to compel was Cal Civ Pro), fees, etc.

I just don't see it as Evidence at all. marry me it feels like 100% PR, PR covers all the privilege, confidentiality stuff.

I agree with not seeing it as an evidence question at all. I thought it was more about understanding the distinctions between A-C privilege and an atty's duty of confidentiality. The CA distinction about the privilige was enough for me to justify why they wanted CA-specific law.

Obviously I could be way off here. I just think that the essays tended to really tee up the issues (like the fraud complaint standard), and it's impossible to do a hearsay analysis without knowing what exactly the attorney would be saying in testimony, or for what purpose it was being offered. Seems strange to me that they'd want us to essentially write a hearsay question ourselves then answer it.

I tend to think the main questions were about PR and privileges, but there were opportunities to discuss Civ Pro and evidence. I think the call of some questions had to do with compelling production of a certain document. Obviously, plaintiff is seeking to potentially submit that as evidence. You could discuss the evidence rules, and also the fact that inadmissible evidence may still be discoverable. Also, work product can only be compelled (remember, the sister is not a client so no privilege or duty of confidentiality there) if plaintiff cannot obtain by other means without unreasonable burden, etc. (not sure if there is a CA distinction here).

[bacillusanthracis]

does a judge need to give detailed opinions as to law and fact for summary judgment? can a judge order summary judgment and then vacate and amend later? can a judge do lickity splits while ordering summary judgment? can a judge affect summary judgment even though the defendant winked twice? what's the standard of review on winking? substantial error? jk that's not a thing, but then again maybe it is

Haha. Right?

I'd gotten to the point where on almost every question I could narrow it down to "Okay, A and B are definitely wrong..." Then you go back, read through the facts again, look for something, and make a pretty safe guess between the remaining two, if not fully isolate the correct answer.

This ... thing? God. Wasn't there anyone in the room when they were putting this together saying,"Hey guys, dontcha' all think this is a little crazy?"

Who knows? Well, I'm off to make excuses to at least two different attorneys at two different firms. I think that telling them, "Hey, I'da rather had whatever three day Bar you took than the meat grinder that was yesterday" wouldn't be received well.

[mambar]

.

[jman77]

I tend to think the main questions were about PR and privileges, but there were opportunities to discuss Civ Pro and evidence. I think the call of some questions had to do with compelling production of a certain document. Obviously, plaintiff is seeking to potentially submit that as evidence. You could discuss the evidence rules, and also the fact that inadmissible evidence may still be discoverable. Also, work product can only be compelled (remember, the sister is not a client so no privilege or duty of confidentiality there) if plaintiff cannot obtain by other means without unreasonable burden, etc. (not sure if there is a CA distinction here).

Wasn't that question phrased to take place at trial (i.e., post-discovery)?

Honestly, I don't remember and you may be right. I guess my overall point is that you're not necessarily constrained to just respond to the obvious calls of the questions. I think it can only help if you discuss other plausible issues as well even if you end up ruling them out based on the facts of the case.

Also, remember that compliance with a court order is one of the exceptions to the duty of confidentiality and the call of the question was whether he may be compelled by the court to produce the document. So you'll have to find a reason the court can't compel him, and to me, that was the work product privilege and the argument that the plaintiff would be able to get the information through some other means without incurring unreasonable costs (wrong rule - should have said plaintiff would not be unfairly prejudiced) because plaintiff can just subpoena the sister (had a separate analysis on how no atty.-client relationship formed between atty. and sister, hence communications with her were not privileged).

Once I was in work product territory, I then proceeded to discuss the rules on work product and when it may/may not be compelled. When I touched on discovery during this analysis, that's when I threw in inadmissible evidence may still be discoverable. From there I went to the admissibility of the document itself. I said something like "even if he is compelled to produce the document, it may yet be inadmissible because it is hearsay...." Heck, I even threw in the best evidence rule (can just testify as to what the sister told him (assuming he is compelled by the court to do so) or must the document itself be submitted).

[mambar]

.

[dimetech]

Quick note from a CA lawyer: privileges are CA evidence, even tho PR touches on duties, confidentiality, etc. FRE 501 (rule re: privilege) specifically references state evidentiary privilege law (is whether it is admissible). So even tho I didn't take the bar and see that question this time, it's likely both evidence and PR.

[Slickrick90]

Man I'm starting to get worried. This is my second crack at the bar. Maybe need 3! Even Lebron needed 3 cracks at the finals before he won! Lol

It is just embarrassing (and a little costly) someone that did well and went to a top school can fail the bar. I can blame the biglaw hours and that I have nothing on the line in terms if I don't pass.

[jman77]

Man I'm starting to get worried. This is my second crack at the bar. Maybe need 3! Even Lebron needed 3 cracks at the finals before he won! Lol

It is just embarrassing (and a little costly) someone that did well and went to a top school can fail the bar. I can blame the biglaw hours and that I have nothing on the line in terms if I don't pass. Maybe I can blame that.

Very understandable. I only had 2 weeks to prepare for the bar as I also worked biglaw hours and had several closings schedule up to the week I started by 2-week bar leave. I just ended up doing a lot of MBE questions and reading and re-reading smartbarprep outlines. I was enrolled in Barbri, but had no time to listen to the lectures or read the materials. Smartbarprep is very useful, by the way. The outlines contain all the rules used in previous exams and rank them according to the frequency with which they appeared. I only had time to go over the "high" frequency rules, but I think that was sufficient. Some of the rule statements were incomplete, but I think sufficient to pass (provided you know how to apply to the facts, of course). Having taken the NY bar 3 years ago also helped to an extent.

[Slickrick90]

Man I'm starting to get worried. This is my second crack at the bar. Maybe need 3! Even Lebron needed 3 cracks at the finals before he won! Lol

It is just embarrassing (and a little costly) someone that did well and went to a top school can fail the bar. I can blame the biglaw hours and that I have nothing on the line in terms if I don't pass. Maybe I can blame that.

Very understandable. I only had 2 weeks to prepare for the bar as I also worked biglaw hours and had several closings schedule up to the week I started by 2-week bar leave. I just ended up doing a lot of MBE questions and reading and re-reading smartbarprep outlines. I was enrolled in Barbri, but had no time to listen to the lectures or read the materials. Smartbarprep is very useful, by the way. The outlines contain all the rules used in previous exams and rank them according to the frequency with which they appeared. I only had time to go over the "high" frequency rules, but I think that was sufficient. Some of the rule statements were incomplete, but I think sufficient to pass (provided you know how to apply to the facts, of course). Having taken the NY bar 3 years ago also helped to an extent.

I used smartbarprep too. That, my buddy's outlines, and the Barbri essay book are all that I used to study lol. I felt like I had a very superficial understanding of the issues. Hence, I didn't write a lot for the essays. I hope I did really well on the MPT. I spent 2 hours on the MPT and 45 mins each on the essay questions.


I did the 1 day exam so I didn't have to worry about MBE issues.

[jman77]

Man I'm starting to get worried. This is my second crack at the bar. Maybe need 3! Even Lebron needed 3 cracks at the finals before he won! Lol

It is just embarrassing (and a little costly) someone that did well and went to a top school can fail the bar. I can blame the biglaw hours and that I have nothing on the line in terms if I don't pass. Maybe I can blame that.

Very understandable. I only had 2 weeks to prepare for the bar as I also worked biglaw hours and had several closings schedule up to the week I started by 2-week bar leave. I just ended up doing a lot of MBE questions and reading and re-reading smartbarprep outlines. I was enrolled in Barbri, but had no time to listen to the lectures or read the materials. Smartbarprep is very useful, by the way. The outlines contain all the rules used in previous exams and rank them according to the frequency with which they appeared. I only had time to go over the "high" frequency rules, but I think that was sufficient. Some of the rule statements were incomplete, but I think sufficient to pass (provided you know how to apply to the facts, of course). Having taken the NY bar 3 years ago also helped to an extent.

I used smartbarprep too. That, my buddy's outlines, and the Barbri essay book are all that I used to study lol. I felt like I had a very superficial understanding of the issues. Hence, I didn't write a lot for the essays. I hope I did really well on the MPT. I spent 2 hours on the MPT and 45 mins each on the essay questions.


I did the 1 day exam so I didn't have to worry about MBE issues.

Honestly, I thought the MPT was pretty straightforward and fairly easy. I think we benefited from the fact that they're still trying to figure out how to go from a 3-hour test to a 1.5-hour one. I only spent an hour on it (wasted time trying to get Softest to work after it froze on me until I finally ended up handwriting the MPT) and still feel good about it. If you spent 2 hours on hit I'm sure you did very well.

The MPT was weird in that there was only one file in the library and the test wasn't a closed universe with made-up jurisdictions and made up rules (you actually had to bring in outside knowledge of the law). But then, maybe that's the way CA MPT's have always been?

[SmokeytheBear]

Man I'm starting to get worried. This is my second crack at the bar. Maybe need 3! Even Lebron needed 3 cracks at the finals before he won! Lol

It is just embarrassing (and a little costly) someone that did well and went to a top school can fail the bar. I can blame the biglaw hours and that I have nothing on the line in terms if I don't pass. Maybe I can blame that.

Very understandable. I only had 2 weeks to prepare for the bar as I also worked biglaw hours and had several closings schedule up to the week I started by 2-week bar leave. I just ended up doing a lot of MBE questions and reading and re-reading smartbarprep outlines. I was enrolled in Barbri, but had no time to listen to the lectures or read the materials. Smartbarprep is very useful, by the way. The outlines contain all the rules used in previous exams and rank them according to the frequency with which they appeared. I only had time to go over the "high" frequency rules, but I think that was sufficient. Some of the rule statements were incomplete, but I think sufficient to pass (provided you know how to apply to the facts, of course). Having taken the NY bar 3 years ago also helped to an extent.

I used smartbarprep too. That, my buddy's outlines, and the Barbri essay book are all that I used to study lol. I felt like I had a very superficial understanding of the issues. Hence, I didn't write a lot for the essays. I hope I did really well on the MPT. I spent 2 hours on the MPT and 45 mins each on the essay questions.


I did the 1 day exam so I didn't have to worry about MBE issues.

Honestly, I thought the MPT was pretty straightforward and fairly easy. I think we benefited from the fact that they're still trying to figure out how to go from a 3-hour test to a 1.5-hour one. I only spent an hour on it (wasted time trying to get Softest to work after it froze on me until I finally ended up handwriting the MPT) and still feel good about it. If you spent 2 hours on hit I'm sure you did very well.

The MPT was weird in that there was only one file in the library and the test wasn't a closed universe with made-up jurisdictions and made up rules (you actually had to bring in outside knowledge of the law). But then, maybe that's the way CA MPT's have always been?

No, you're not supposed to bring in outside knowledge of the law. Often times the law of the MPT universe will be parallel if not the same as real law. But the exercise is supposed to be closed universe.

[cnk1220]

Man I'm starting to get worried. This is my second crack at the bar. Maybe need 3! Even Lebron needed 3 cracks at the finals before he won! Lol

It is just embarrassing (and a little costly) someone that did well and went to a top school can fail the bar. I can blame the biglaw hours and that I have nothing on the line in terms if I don't pass. Maybe I can blame that.

Very understandable. I only had 2 weeks to prepare for the bar as I also worked biglaw hours and had several closings schedule up to the week I started by 2-week bar leave. I just ended up doing a lot of MBE questions and reading and re-reading smartbarprep outlines. I was enrolled in Barbri, but had no time to listen to the lectures or read the materials. Smartbarprep is very useful, by the way. The outlines contain all the rules used in previous exams and rank them according to the frequency with which they appeared. I only had time to go over the "high" frequency rules, but I think that was sufficient. Some of the rule statements were incomplete, but I think sufficient to pass (provided you know how to apply to the facts, of course). Having taken the NY bar 3 years ago also helped to an extent.

I used smartbarprep too. That, my buddy's outlines, and the Barbri essay book are all that I used to study lol. I felt like I had a very superficial understanding of the issues. Hence, I didn't write a lot for the essays. I hope I did really well on the MPT. I spent 2 hours on the MPT and 45 mins each on the essay questions.


I did the 1 day exam so I didn't have to worry about MBE issues.

Honestly, I thought the MPT was pretty straightforward and fairly easy. I think we benefited from the fact that they're still trying to figure out how to go from a 3-hour test to a 1.5-hour one. I only spent an hour on it (wasted time trying to get Softest to work after it froze on me until I finally ended up handwriting the MPT) and still feel good about it. If you spent 2 hours on hit I'm sure you did very well.

The MPT was weird in that there was only one file in the library and the test wasn't a closed universe with made-up jurisdictions and made up rules (you actually had to bring in outside knowledge of the law). But then, maybe that's the way CA MPT's have always been?

No, you're not supposed to bring in outside knowledge of the law. Often times the law of the MPT universe will be parallel if not the same as real law. But the exercise is supposed to be closed universe.

I've seen some practice MPTs (granted this was when I was studying for the UBE) were sometimes the law in the case file is actually slightly wrong to test if you will bring in outside knowledge of the law or follow directions and apply only the law in your file. The PTs are supposed to be 100% closed universe- everything you need is in the file they give you.

[dimetech]

CA doesn't administer an MPT (multistate performance test). They make up their own.

[maxmartin]

Man I'm starting to get worried. This is my second crack at the bar. Maybe need 3! Even Lebron needed 3 cracks at the finals before he won! Lol

It is just embarrassing (and a little costly) someone that did well and went to a top school can fail the bar. I can blame the biglaw hours and that I have nothing on the line in terms if I don't pass. Maybe I can blame that.

Very understandable. I only had 2 weeks to prepare for the bar as I also worked biglaw hours and had several closings schedule up to the week I started by 2-week bar leave. I just ended up doing a lot of MBE questions and reading and re-reading smartbarprep outlines. I was enrolled in Barbri, but had no time to listen to the lectures or read the materials. Smartbarprep is very useful, by the way. The outlines contain all the rules used in previous exams and rank them according to the frequency with which they appeared. I only had time to go over the "high" frequency rules, but I think that was sufficient. Some of the rule statements were incomplete, but I think sufficient to pass (provided you know how to apply to the facts, of course). Having taken the NY bar 3 years ago also helped to an extent.

I used smartbarprep too. That, my buddy's outlines, and the Barbri essay book are all that I used to study lol. I felt like I had a very superficial understanding of the issues. Hence, I didn't write a lot for the essays. I hope I did really well on the MPT. I spent 2 hours on the MPT and 45 mins each on the essay questions.


I did the 1 day exam so I didn't have to worry about MBE issues.

Honestly, I thought the MPT was pretty straightforward and fairly easy. I think we benefited from the fact that they're still trying to figure out how to go from a 3-hour test to a 1.5-hour one. I only spent an hour on it (wasted time trying to get Softest to work after it froze on me until I finally ended up handwriting the MPT) and still feel good about it. If you spent 2 hours on hit I'm sure you did very well.

The MPT was weird in that there was only one file in the library and the test wasn't a closed universe with made-up jurisdictions and made up rules (you actually had to bring in outside knowledge of the law). But then, maybe that's the way CA MPT's have always been?

No, you're not supposed to bring in outside knowledge of the law. Often times the law of the MPT universe will be parallel if not the same as real law. But the exercise is supposed to be closed universe.

Wrong, the instruction specifically (maybe always) said you can supply outside legal principle and knowledge. In 3 hours exam, the material within is so much, no one really bothers but I do see released good answers having outside law or knowledge. But this MPT I fear you have to bring a lot outside stuff.